Privacy Policy

CPA Professional Liability Plan Inc., operating as ACPAI Insurance in the province of Quebec, (“CPA PLI”, “we”, “our”, or “us”) is committed to protecting your privacy and treating your personal information fairly and with respect. We have developed this privacy policy to let you know how we treat the personal information we collect, use and disclose in the administration of our professional liability insurance program (the “Program”) or when you otherwise interact with us.

What is Personal Information?

“Personal information” means information about you that can be used, alone or with some other available information, to identify you. For example, personal information may include your name, home contact information, qualification and date of qualification, previous insurance history, information pertaining to past, current or potential insurance experience or claims, and financial information.

Certain information may be excluded from the scope of “personal information”. For example, business contact information that relates to or is solely used to communicate with you in relation to your employment, business or profession, such as your position name or title, work address, and work telephone number, and certain publicly available information, such as telephone directory listings, may be excluded in certain circumstances from the scope of “personal information”.

Our privacy practices regarding personal information about our employees or candidates for employment are set out in internal CPA PLI policy documents. Therefore, this information is excluded from the scope of this policy

What Personal Information does CPA PLI Collect?

We may collect the following personal information, depending on our relationship with you:

  • If you apply for or use our insurance products, we may collect information such as your name, business contact information including business name, mailing address, phone number and email address, work history, claims history, date of CPA qualification and member number, names of persons with whom you may have a business relationship, and names of persons in whom you may have a financial interest. We may also collect your personal email address and mobile phone number.
  • If you subscribe to our mailing list, we may collect your contact information through our subscription form, such as your name and email address, and information about your preferences for receiving our newsletter and other member communications.
  • If you use and interact with our website or emails, we automatically collect information about your device and your usage of our website through cookies and similar tracking technologies (see the “Cookies” section below for more information).

Whenever it is practical for us to do so, we collect personal information directly from you or your authorized representative, such as through our application and registration forms, whether online or in paper format. In some cases, we may obtain personal information from third party sources, such as industry associations and your employer. CPA PLI may collect such information itself, or our Program Facilitators may collect this information from you on our behalf.

We also collect, use, and share aggregated and anonymized data for various purposes, including for internal research and analysis. Aggregated and anonymized data is not considered personal information because it cannot be used to identify you. 

How CPA PLI Uses Personal Information

We generally use your personal information to serve your professional liability insurance needs and to administer the Program. We use personal information only for purposes a reasonable person would consider appropriate in the circumstances.

Specifically, we use personal information for the purposes of:

  • evaluating, monitoring and assessing your insurance needs;
  • evaluating your application, particularly with respect to insurance risks being undertaken;
  • processing, rating, binding and issuing your policy;
  • amending, adjusting and assessing coverage;
  • providing all policy related or administrative services, including loss control and handling, investigating and resolving claims;
  • providing ongoing risk management services;
  • administering the Program, including negotiating and assessing insurance premiums, as well as compiling statistical data used on an ongoing basis to set premiums and provide risk management services;
  • communicating with you to offer our services on an ongoing basis; and
  • complying with legal and regulatory requirements, or as authorized or required by law.

To Whom Do We Transfer or Disclose Your Personal Information?

We work with third parties that assist us in providing the Program, including the participating insurers, reinsurers, insurance brokers or agents, actuaries, claims adjusters, lawyers, investigators and experts or other consultants (“Program Facilitators”). We may transfer your personal information to the Program Facilitators, and the Program Facilitators may collect your personal information on our behalf, for the purposes of the Program.  We may also transfer your personal information to third parties involved in handling claims for the purposes of the Program.

We disclose basic policy information, including your name and the number, limit and expiry date of your policy, to your provincial CPA association for the purpose of providing them with proof of the existence and status of your professional liability insurance. For members practicing in Quebec, we also provide the Ordre des comptables professionnels agréés du Québec with a copy of your policy. We disclose this information as part of our service to you to assist you in meeting your provincial regulatory requirements. You may withdraw consent to this disclosure by notifying us in writing at the time of application for insurance (see the “Withdrawing Consent” section below for more information).

Under the terms of your insurance policy, we are required to notify your provincial CPA association in the event of cancellation or non-renewal of your policy for any reason.

We may also disclose your personal information:

  1. in connection with a business transaction, such as the purchase, sale or other acquisition or disposition of our business;
  2. where permitted or required by law or by a court, administrative agency or other governmental tribunal; and
  3. for such other purposes as you may consent from time to time.

We do not sell your personal information to third parties.

Cookies

We use cookies and similar tracking technologies to automatically collect certain device and usage data when you use our website. This information is not usually personal information that can be used to identify you.

Cookies are small files which are sent to your Web browser and stored on your computer’s hard drive. The cookie stores certain information about your computer or mobile device and your use of our website. We only use cookies within the Client Area on our website which can only be accessed by secure login. We use these cookies to help us recognize you as a user of that area of our website and to help improve your user experience. The cookies last for the duration of your user session and are not permanently stored on your computer system after your browser is closed.

Depending on your geographic location, we may or may not be required under law to provide you with specific notice or to ask your opt-in consent before using certain advertising and analytics cookies. In any case, you may still set your web browser to notify you of cookie placement requests or to decline cookies completely. However, doing so may prevent you from enjoying optimal functionality otherwise available to users of the Client Area of our website.

Your Consent

We only collect, use and disclose your personal information with your consent or as otherwise required or permitted by law.

How we obtain your consent, including whether it is express or implied, will depend on the circumstances and the sensitivity of the personal information in question. Your consent may be expressed in writing, given verbally, electronically, or through an authorized representative, including your firm’s managing partner or legal representative.

In most cases, consent to collect, use and disclose personal information is obtained from the person applying for, renewing or revising your insurance coverage. If an application and/or policy covers more than one individual, we ask the individual applying for the insurance or signing the applicable form to confirm that the consent of all potential insureds has been obtained and/or that such individual has been appointed by them as their representative with authority to provide such consent on their behalf. CPA PLI will rely on this advice as it applies to you and your personal information unless you instruct us otherwise.

Withdrawing Consent

Please contact us using the contact information below if you wish to discuss withdrawing your consent and the implications of withdrawing your consent.

Your decision to withdraw consent to the collection, use or disclosure of your personal information may limit the services we are able to provide. Due to the nature of the Program and the insurance our insureds request from us, once we issue an insurance policy for you, it may not be possible to withdraw your prior consent, if you wish to maintain insurance with CPA PLI.

Safeguarding Your Personal Information and Location of Processing

CPA PLI maintains appropriate physical, organizational and technological security safeguards in an effort to protect your personal information. For example:

  • Access to personal information is limited to employees and authorized service providers who need it to perform their work.
  • CPA PLI makes its employees aware of the importance of maintaining the confidentiality of personal information and our employees receive training in proper information handling practices.
  • CPA PLI protects personal information in electronic form using technological means such as firewalls, access controls, and encryption.
  • CPA PLI uses contractual or other means, as appropriate, to maintain adequate safeguards to protect the security of your personal information transferred to third parties for processing.

Your personal information may be processed by one or more of our third party service providers in one or more countries outside your originating province, including outside of Canada. While your personal information is outside of Canada, it may be subject to the laws of the country in which it is held, which may have different data protection laws than Canada. If you have any questions about our policies and practices regarding service providers outside of Canada, please contact our Privacy Office. Contact information is provided below.

Despite these measures, we cannot guarantee that our safeguards will always be effective. A breach of security safeguards can result in risks such as phishing and identity theft. In such cases, we will act promptly to mitigate the risks and to inform you where there is a real risk of significant harm, or as otherwise required by law.

We may also require that you assist us in safeguarding your personal information. For example, if you create a client account through our website, you should use a unique and strong password and not share your password with others. 

If you have reason to believe that your personal information is no longer secure, please contact us immediately using the contact information below.

Retention of Personal Information

CPA PLI will retain personal information for as long as is necessary to fulfil the purposes for which it was collected and as permitted or required by law. After it is no longer needed for these purposes, the information will be securely deleted or disposed of.

Third-Party Websites and Services

We may provide links to third-party websites for your convenience and information. We may also make opportunities available to you to purchase, subscribe to, or use other products or services from third parties with different privacy practices. Those other websites, products, or services are governed by the privacy statements and policies of the respective third party. This policy does not extend to any websites, products, or services provided by third parties. We do not assume responsibility for the privacy practices of third parties and we encourage you to review all third-party privacy statements prior to using third-party websites, products, or services.

Your Privacy Rights

We expect you to supply us with updates to your personal information, when required. We will not routinely update your personal information unless such a process is necessary.  

You may make a request to review any personal information about you that we have collected, used, or disclosed, and we will provide you with any such personal information to the extent required by applicable laws. Upon request, and to the extent required by law, we will also provide you with details about categories of persons who have access to your personal information within CPA PLI and the duration of time your personal information will be retained.

You may also challenge the accuracy or completeness of your personal information in our records. If you demonstrate that your personal information in our records is inaccurate, incomplete or equivocal, or that the collection, use or disclosure of your personal information is not authorized by law, we will amend or delete your personal information as required by applicable law. Where appropriate, we will transmit the amended information to third parties to whom we have disclosed your personal information.

Before processing a request for access to or correction or deletion of your personal information, we may require that you provide certain information to confirm your identity to our satisfaction and fulfil your request. We will not charge you any fees in connection with your request without first providing you with an estimate of the approximate fees, if any

If you object to how we handle your request, you may have the right to make a complaint to the Privacy Commissioner of Canada or the applicable provincial privacy commissioner.

How to Contact Us

If you have any questions, concerns or requests regarding your personal information or our privacy practices, please contact us at the address below:

Privacy Office

CPA Professional Liability Plan Inc.

702-277 Wellington Street West

Toronto, Ontario M5V 3H2

privacy.office@cpaplan.ca

Amendments

This Policy may be amended from time to time at CPA PLI’s discretion. We encourage you to check this location frequently for any updates or amendments to this policy. When changes are made, they will become immediately effective when published in a revised policy posted on our website, unless otherwise noted. We may also communicate changes to this policy by other means.

Last revised March 2024

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